The IRS has decided to sue Facebook. The central issue is the IRS belief that Ernst & Young, Facebook's accounting firm, purposefully understated value in the transfer pricing of assets transferred to Facebook's Irish corporate entity. Transfer pricing may be the central legal and accounting issue that determines millions if...
Blog
The IRS has Begun Data Mining for Offshore FBAR Audit Targets
It's official. The FBAR audit warnings and IRS data mining you've been reading about in this space for the past several years have been confirmed by the Wall Street Journal (WSJ): U.S. Mining Swiss Bank Data to Find Tax Cheats It wasn't a question of "if" it was a question...
How Can an Experienced San Diego IRS Audit Attorney Help You?
One of the first questions a taxpayer will ask themselves after receiving a "Letter of Notification" from the IRS regarding an audit is "Do I need an attorney?" How can an experienced San Diego IRS audit attorney help you, and is it worth the money it may cost? The first...
What Impact will the Inspector General’s Report Have on the OVDP and Offshore IRS Violators?
The Inspector General's office recently released a scathing report accusing the IRS of missing more than $39 Million in uncollected offshore tax revenues. The report harshly criticized the IRS' complete failure to follow up on rejected OVDP and offshore IRS violators as well as internal assignment of personnel based upon...
IRS Missed $39 Million in OVDP Penalties
The US Treasury Department's Inspector General for Tax Administration has determined that the IRS missed an opportunity to collect over $39 Million in OVDP penalties from taxpayers who were either rejected or withdrew their application to the OVDP or Offshore Voluntary Disclosure Program. In a press release, Inspector General J....
IRS to Retire PIN System – How to Protect Your Business Information
The IRS announced plans to retire the automated PIN system for filing returns electronically, due to extensive hacking and compromised personal and business information of more than half a million US taxpayers. Despite its best efforts the IRS has not been able to protect your business information or your personal...
FBAR Electronic Filing Due June 30 – No Extensions
If you had a financial interest in a foreign financial account, or signatory or authority over one or more accounts whose aggregate value exceeded $10,000 USD at any point in 2015, you are required to file an IRS FBAR (Report of Foreign Bank and Financial Accounts). You must submit the FBAR...
Buying a Business in San Diego
What is the best strategy to acquire a business or purchase a competitor? Buying a business in San Diego is legally quite complex, and the experienced business advisers and attorneys at Allen Barron will guide you through the process. Mergers and acquisitions are structured to provide our clients with the...
What is the Offshore Voluntary Disclosure Program or OVDP in San Diego?
What do US taxpayers in San Diego need to know about the IRS Offshore Voluntary Disclosure Program or OVDP and how can it be the safest option for disclosing previously unreported offshore accounts, assets and income? The IRS Offshore Voluntary Disclosure Program is exactly what it sounds like - a...